K & SON BAG CO., INC., ET AL File No: AOD/AOD Number not available. November 16, 1970 Decision: Court not available., Dkt. Nos.: 2930-67; 2931-67;, T.C. Memo. 1970-177 Internal Control No.: CC:BUF-TC JW Uniform Issue List Information: Uniform Issue List Nos: 0061.25-02 0162.03-01 0162.15-02 0061.17-

quired and that the taxpayer only needs to have "a profit" objective. Faulconer v. Comm'r, 748 F.2d 890 n.10 (4th Cir. 19841. 5. Schwartz v. Comm% T.C. Memo 2003.86. 6. Treas. Reg. § 1.183.2(b). These nine factors were applied by the Tax Court in the case of Rabinowitz v. Commissioner, T.C. Memo 2005.1

use of the Final Decree. Since Sumner was relying on the advice of competent professionals, no penalties were added. Somewhere, Edward is smiling. T.C. Memo. 2015-237 (December 9.2015) • Mt Hall is a Managing Director of FMV Opinions. Inc.. a national valuation and investment banking firm with offices in

rminate the Agreements and preserve the special tax treatment. This proposal is illustrated as Proposal One on the attached chart. Neff v. Comm sr, T.C. Memo. 2012-244 (TC 2012). EFTA_R1_01971649 EFTA02677249 Comparison of Split-Dollar Insurance Proposals December I I, 2013 Proposal One—Rollout witho